Comment 8:  Regarding 9 VAC 20-160-110.J., I agree wholeheartedly with Mr. Thornhill's comment 17.  Moreover, what does the word "register" mean?  What is the mechanism by which one is supposed to "register" the fact of a transfer of ownership with the department?

Comment 9:  Regarding 9 VAC 20-160-120.A., the department previously used initial caps on the words "site characterization report."  See 9 VAC 20-160-70.A.1.  For the sake of consistency, it should do so here. 

Comment 10:  In 9 VAC 20-160-120.B.2., delete "VRP" before the word "project."  Although we all know what "VRP"means, it is not a defined term in the regulations and is not used elsewhere in the regulations.  In contrast, the word "project" is used elsewhere in the regulations. 

I appreciate the opportunity to comment on the proposed regulations.  I may be reached at 804-420-6422 or cmartin@williamsmullen.com.

                                                                         Channing Martin